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Final picture of FIC compliance emerging

The third in a series of quarterly reports commissioned by GS1 UK, which show a snapshot of progress by analysing a basket of 20 products*, found positive signs that industry is making significant progress toward compliance. For the first report in April, four of the 20 products were compliant, rising to eight in July and 11 in this final report.

However there are still a handful of reoccurring issues that have been identified throughout this work – products supplied from outside the EU have consistently been found to be non-compliant for all three reports, for example.

The following trends were noted from our research:

  • Still work to be done – While there has been an overall increase in compliancy in the sample baskets, larger companies are still showing mixed levels of compliance. This is to be somewhat expected, with larger companies potentially having to work through thousands of product lines running right up to the deadline.
  • Increasing compliance with controversial products – Both wheat flour fortification and allergen labelling have been subject to much debate a in light of the FIC regulation, therefore it is encouraging to find there has been a noticeable rise in compliance as industry settles on common approaches to these problem areas.
  • Specific date requirements often overlooked – There is a new requirement found in FIC to indicate the date of first freezing, consisting of the day, month and year in uncoded form and preceded by the words ‘Frozen on …’.  Not all frozen foods need to have a date of first freezing; it is only required on frozen meat, frozen meat preparations and frozen unprocessed fishery products. However, our research shows that some products are currently missing these date requirements entirely. Additionally, special storage conditions must also be indicated after the date itself, which has been causing some products to fall short of compliance.

While the report shows a number of products were not compliant with the regulation, it does not necessarily mean these companies will miss the deadline. It must be noted that some non-compliance could be because brand owners are taking full advantage of the transition time allowed them to phase in new packaging, or they understandably wish to minimise unwelcome wastage and are therefore giving themselves as much time as possible.

When the FIC Regulation is enforced on 13 December, the only products where non-complaint labels are acceptable are on those which have been made and labelled prior to the deadline date, to enable stock already in the supply chain or on shelves to run through. Products found with illegitimate labels will be offered advice and improvement notices, and persistent failure to comply with FIC after 13 December 2014 will be an offence.

Gary Lynch, CEO of GS1 UK: “This series of reports has shown encouraging signs that industry is moving toward compliance. This is a costly and complex exercise for many, but food and drink businesses have been taking it very seriously and we believe that it will benefit the customer by providing them with a greater understanding of the products they are purchasing – which will ultimately be positive for businesses. While we are confident that most will achieve compliance in time, that is only the beginning – getting the processes in place to ensure it is maintained for all product changes and new launches will be a key consideration.”

You can view a copy of the GS1 UK / Campden BRI analysis report HERE

Looking forward, there is still plenty to be aware of beyond the principal transition measure date of 13 December 2014. The first of the implementing regulations tackling origin labelling on popular meats other than beef becomes effective from 1 April 2015.


Notes to Editors

* The 20 samples were taken across four food categories, those categories being the same as the ones checked in the April survey:

  • Prepared ready meals
  • Primary foods (meat and fruit)
  • Confectionery and gift foods
  • Flour and flour-based products

A wide range of retail outlets were visited to purchase samples:-

  • Premium retailers
  • High street retailer
  • Discounter
  • Farm shop
  • Department store
  • Garden centre

GS1 commissioned Campden BRI to undertake the survey.


(Q) When does FIC apply?

(A) There are several transition dates in the FIC and associated legislation but they do not need to be treated as absolute deadlines. It is important to note that retailers may well find themselves receiving goods that do not comply into their warehouses after those dates. This is perfectly acceptable so long as those products have been placed on the market or labelled prior to that date. In reality we can expect to find ‘old-style’ products on retail shelves for some while after the FIC transition measure deadline, particularly if they have long shelf lives like canned goods or frozen products.

(Q) Will traffic light labelling be mandatory?

(A) No. The FIC makes clear that the labelling of nutrition information becomes mandatory on most products, though not all as certain exemptions apply as discussed in the July survey report. The mandatory information is the familiar nutrition table normally found on the back of the pack. Traffic light nutrition labelling is located on the front of pack and it is entirely voluntary.

(Q) When will nutrition information be mandatory?

(A) From the 13th December 2016, but if nutrition information is declared prior to that date then it must be done in a manner consistent with the requirements of the FIC.

About GS1 UK

For more than 35 years GS1 UK has been working with its members to enable the efficient movement of goods and sharing of information. It drives supply chain efficiency alongside 111 other not-for-profit GS1 member organisations in 150 countries worldwide.

Having introduced the first truly global bar code numbering system in 1973, at least five billion GS1-compliant bar codes are now scanned everyday – making it the most widely used supply chain standards system in the world. GS1 identification numbers are now also commonly used in RFID tags, Electronic Data Interchange (EDI) messages and for real-time global data exchange.

Providing independent support, GS1’s team of technical and business consultants also assist members with on-site implementation of appropriate supply chain information solutions.

Its 28,000+ UK members range from SMEs to major UK companies and include grocery retailers and food service companies, food manufacturers, healthcare and pharmaceuticals companies, and NHS Trusts. Its supervisory board includes senior directors from Tesco, Morrisons and Sainsbury’s, as well as Unilever, P&G, Diageo and the NHS.

GS1 UK actively supports The Food Chain – a UK charity set up to ensure that people living with HIV can access the nutrition they need to lead healthy, independent lives. For more information, visit